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FinCEN making more changes to CTR filing instructions

FinCEN ruling FIN-2020-R001, dated Monday, announced Tuesday and effective April 6, 2020 (September 1, 2020 for e-filing batch filers), makes significant changes in CTR filing requirements for transactions involving sole proprietorships and legal entities operating under a "doing business as" (DBA) name. FinCEN states that the changes are being made "to both enhance regulatory efficiency and provide complete and accurate CTR data to law enforcement."

    Sole proprietorships

    • When a sole proprietorship is involved, items 4 through 7 and item 17 (name, gender and date of birth) are those of the individual owner.
    • In states that allow spouses to jointly operate a sole proprietorship, identify the individual whose SSN is attached to the sole proprietorship
    • If the sole proprietor does business in his/her own name, the rest of Part I should reflect the individual owner's information.
    • If the individual owner operates the business under a different name (a DBA name), the DBA name appears in item 8 (alternate name), and complete the rest of Part I (other than items 4-6, 7 and 17) with reference to the DBA name and location of that business
    • If more than one DBA business is involved in the sole proprietor's reported transactions, list only one DBA name in item 8 and complete a separate Part I for each involved DBA business
    • The amount and account number(s) in Items 21 and/or 22 will be the amount an account number(s) associated with the specific location for the reported transaction.

    Legal entities

    • When a CTR is prepared on a legal entity such as a partnership, corporation, or LLC , etc., the Part I section should reflect home office/headquarters data (address, phone number, ID number, etc.) of the entity.
    • When multiple entity locations are involved, a separate Part I section should be prepared for each location involved.
    • Those additional Part I sections should include the entity's legal name in item 4 and alternative name, if any, in item 8.
    • Only one DBA name per Part I. If multiple DBAs are involved, use a separate Part I for each DBA and no DBA name should appear on the Part I for the home office/headquarters.
    • Each of the additional Part I sections will identify the location's address along with other entity data applicable to that location (phone number, etc.)
    • The initial Part I section on the entity home office will show total amount and all account numbers involved in item 21 or 22. The Part I entries for multiple locations will show account number(s) and amounts associated with that location only.

    The new ruling rescinds and replaces FIN-2006-R003 and FIN-2008-R001, both of which were based on the old CTR Form 104.

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